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Message
From:
Sent:
To:
i; Rodric Williams
Atan [
GRO $ Angela Van-Den-Bogerd:
Andrew Parsons
Henderson, Tom
Veronica Branton}
Subject: RE: Legally Privileged - GLO sub-committee
Attachments: GLO Sub-Committee Meeting Agenda.docx; Legally Privileged and Confidential - DRAFT Legal workshop
outputs_UPDAT....pdf
¥
Thanks Ben,
Attached is:
1) The draft agenda for comments and improvements ~ as circulated earlier by Aimee
2) A first cut of the Horizon Issues Trial Contingency Planning deck which can be folded into the wider presentation
you refer to below. The drafting needs to be refined and can be updated subsequent to the workshops
scheduled for tomorrow and Thursday — but I thought you would appreciate being sighted early on this.
Mark
\ Mark Underwood
Portfolio Director: Legal, Risk & Governance
Ground Floor
2017 Winner of the Global Postal Award 2° Finsbury Street
Loridon EC2Y 9AQ
for Customer Experience
Mobile number
From: Ben Foat
Sent: 04 June 2019 20:17
To: Rodric Williams <.
; andrew.parsons <!
Henderson, Tot
an-Den-Bogerd
Watts, Alan
Angela V:
; Diane Blanchard
See Al’s email which I think is really helpful in shaping the settlement agenda item. I know that WBD have prepared the
settlement slides and advice but I think Al’s request goes much further than that. I suspect that it would need the
involvement of someone in Finance — probably Cathy Mayor Retail Finance FD.
Subject HSF’s view, Rod and Andy can you prepare a pack/ paper for the Board subcommittee including the settlement
approach as outlined below.
I think this will need a paper or presentation given that it needs to cover:
- the questions that Kelly Tolhurst raised; ie revised strategy for going forward with new counsel team and
approach on tone and style. [HSF] This should include the privilege point in Al’s email [Rod — you can outline the
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existing approach and any recommendations for the meeting ie circulate but collect documents after the
meeting]
- Settlement approach; costings; approach; operational implications (PPI claims ie managing future claims etc) [
Andy/ Rod / HSF]
- Horizon Contingency Planning [Mark / Angela]
Approaches on Historic suspension claims [Andy]
Mark has circulated an agenda yesterday with the topics but we need a paper to pull this together by COB this week.
Di — can you confirm the day and time of the Board Subcommittee for next week.
Ben Foat
General Counsel
Post Office Limited
From: Alisdair Cameron
Sent: Tuesday, June 4, 2019 6:40:02 PM
To: Watts, Alan; Ben Foat
Cc: Thomas Cooper
Subject: Legally Privileged - GLO sub-committee
Alan, Ben
We need to use the GLO sub-committee next week for a variety of things, as discussed, including preparation
for the Ministerial meeting with Kelly Tolhurst.
There is understandably real disquiet about the litigation in terms of cost, brand damage and whether we
have a grip on it. The failed recusal makes us look as though the change rhetoric was just that.
We do need to find a way of landing the degree of change and also explain the logic of the recusal, without
getting left in the historical limbo.
Most importantly, we need to set out a strategy where settlement in now Plan A and a good bank/bad bank
split may be the right choice for further, historical claims. It is important that we take them through the
challenges and costs which are split between
- This case
- The likely future litigation or other historical claims
- The cost of managing the business differently
- The implications and super-costs if we had convictions overturned by the CCRC
Aclear timetable of decisions and windows and preferences will be critical to the documentation. I am anxious
that privilege may not survive contact with a political process so can you agree how we share — is it just in the
room and verbal, in the room and content destroyed or pre-read?
We are going to have to do numbers, without creating anything that we are not happy putting into the
accounts. We could do a table covering legal fees, payments, further claims etc.
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One approach would be to start with the original Plan A —5 trials, numerically reduce the claimants through
over 6 years, full settlement etc, possibly pay something for suspension and limited other impacts — say £40-
50m from now?
Then the cost of settlement, adjusting for the Judge’s likely perspective and also a cost plus model for the
claimants.
Then the costs of historical and follow on claims
Then the critical issue of how we run the business and what it looks like if we shift burden of proof to us
Then the super costs if convictions are overturned or we are found to have damaged people.
Then we will need to do some rapid high level work on how much we could cover.
In other words a really sensible and full attempt to answer her questions.
Happy to discuss. I am in branches tomorrow but can sit down Thursday. Tom, anything to add?
Thanks Al
Al Cameron
Interim Chief Executive
20 Finsbury Street
London
EC2Y 9AQ
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